TRAINING AND EMPLOYMENT

NOTICE

NO. 3-18, Change 1

DATE June 25, 2019

EMPLOYMENT AND TRAINING ADMINISTRATION

U.S. DEPARTMENT OF LABOR

WASHINGTON, D.C. 20210

TO: STATE GOVERNORS

ALL STATE LABOR COMMISSIONERS

ALL STATE APPRENTICESHIP AGENCIES

ALL STATE WORKFORCE AGENCIES

STATE AND LOCAL WORKFORCE BOARD CHAIRS AND DIRECTORS

FROM: MOLLY CONWAY /s/Acting Assistant Secretary

SUBJECT: Creating Industry-Recognized Apprenticeship Programs to Expand Opportunity in America

1. Purpose.

In June 2017, President Donald J. Trump signed an Executive Order (EO) on

Expanding Apprenticeships in America, which lays out an expanded vision for

apprenticeship in America. This revised Training and Employment Notice (TEN)

provides additional information on a framework for an important part of this expanded

approach: Industry-Recognized Apprenticeship Programs.1 The TEN has been revised

to provide additional information concerning high-quality apprenticeships and what is

necessary to support them. This revised TEN will subsequently be accompanied by a

revised and finalized application form, which the Department of Labor (Department or

DOL) will announce as available through www.apprenticeship.gov. The Department

will accept submissions through this form from entities interested in receiving a

favorable determination that their characteristics, policies, and procedures align with

the features this TEN describes.2 The Department encourages entities to continue to

develop plans, structures, and key partnerships that will form the basis for a successful

submission.

The Administration’s initiative encourages entities such as trade, industry, and

employer groups and associations; companies; certification bodies; educational

institutions (such as universities or community colleges); state and local government

agencies or entities; non-profit organizations; unions; joint labor-management

organizations; or a consortium or partnership of entities such as those listed above to

collaborate to create new, industry-driven apprenticeship solutions. Standards

1 The TEN was initially issued in July 2018. 2 This revised TEN’s form is consistent with the separate, proposed application form the Department has published

in connection with the Department’s recent Notice of Proposed Rulemaking (NPRM). To the extent the application

form for the final rule differs from the TEN’s form, the final rule may provide that entities that have received a

favorable determination under the TEN should provide updated application information to the Department.

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Recognition Entities3 (SREs) of Industry-Recognized Apprenticeship Programs will be

a critical part of the initiative. They will evaluate, recognize, and ensure the high quality

of apprenticeship programs administered by entities such as companies, trade and

industry groups, non-profit organizations, educational institutions, unions, and joint-

labor management organizations. SREs may also develop off-the-shelf apprenticeship

products for apprenticeship programs to use. This revised TEN sets out, at a high

level, the policies and procedures that SREs are expected to have in place to

establish their standards-setting and recognition processes and to evaluate and

recognize apprenticeship programs as high quality.4 Organizations will be able to

seek a favorable determination from the Department that their standards-setting and

apprenticeship recognition practices are consistent with this TEN’s criteria and, in so

doing, help ensure that programs they recognize are high-quality programs. In

reviewing requests for such a determination, the Department will assess each SRE’s

quality while accounting for the fact that high-quality apprenticeship programs may

take different forms in different industry sectors and occupational areas. Thus, the

Department will not seek to dictate directly what each SRE’s industry- or occupation-

specific standards should be. This approach means that employers, non-profit

associations, unions, labor-management organizations, and other stakeholders involved

in each industry and occupational area will have the freedom to design apprenticeship

programs that best fit their needs, bringing flexibility and innovation to the

apprenticeship model. At the same time, the Department will provide a favorable

determination only to entities that have the features outlined below, including what is

needed for apprenticeship programs characterized by the hallmarks of high quality.

2. References. National Apprenticeship Act (29 U.S.C. § 50); and Executive Order 13801, “Expanding Apprenticeships in America,” June 15, 2017 (82 FR 28229).

3. Overview and Introduction.

Apprenticeship is a proven pathway to great careers in the United States.5

Apprenticeship is an arrangement that includes a paid-work component and an

3 The Department uses the term “Standards Recognition Entities” (SREs) to refer to entities that have the

characteristics outlined in this revised TEN, entities that in turn recognize Industry-Recognized Apprenticeship

Programs as having the hallmarks of high-quality apprenticeship programs. “Standards Recognition Entity”

replaces the terms “certifier” and “accreditor” that the Department used previously. 4 This TEN does not create any rights, responsibilities, or benefits for SREs that receive favorable determinations

from the Department under this TEN. The Department’s recent NPRM separately proposes rules for the

Department’s formal recognition of SREs, and the responsibilities of Department-recognized SREs. Given the

skills gap and the need for action, this revised TEN and the form associated with it are intended to encourage

continued development of SREs and Industry-Recognized Apprenticeship Programs, and to permit entities

interested in applying to the upcoming program to engage with DOL about their standards-setting and recognition

processes. The Department will use the form as a mechanism to enable entities to seek a favorable determination

about whether the information provided is consistent with the criteria outlined in this TEN. 5 See A. Elejalde-Ruiz, Apprenticeship Programs Enjoy New Life as a Workplace Solution, Chicago Tribune (Oct. 26, 2017), available at http://www.chicagotribune.com/business/ct-biz-apprenticeship-expansion-1029-story.html; N. Wyman, Why Investing in Apprenticeship Makes Good Dollars and Sense, Forbes (Nov. 1, 2016), available at https://www.forbes.com/sites/nicholaswyman/2016/11/01/why-investing-in-apprenticeship-makes-good-dollars-and-sense/#13c040d85de0.

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educational or instructional component, wherein an individual obtains workplace-relevant knowledge and skills.6

Apprenticeship programs in some industries, such as construction, are registered under

29 CFR part 29, and certain occupations have embraced the earn-as-you-learn approach

for decades. However, the American workforce is changing, and there has been a surge

of opportunities in emerging sectors, such as information technology, advanced

manufacturing, healthcare, and financial services, without the corresponding growth in

the skilled workforce to fill job vacancies.7 Especially in light of the rising cost of

higher education and the swelling debt that burdens many college graduates,

apprenticeship is an efficient and economical solution both to give workers the skills

they need for the jobs of today and the future and to meet employers’ needs for a skilled

labor force.

This revised TEN is an important step toward advancing the new, high-quality

apprenticeship programs needed to support a new American economy and current

labor market needs. This revised TEN carries out the directive in EO 13801,

Expanding Apprenticeships in America, by providing additional information on the

policies and procedures SREs should have in place to set standards for and recognize

the high quality of apprenticeship programs, focusing on industries without significant

Registered Apprenticeship opportunities. This TEN is guided by, and largely based on,

relevant recommendations offered in the Final Report of the President’s Task Force

on Apprenticeship Expansion (Final Report).

Executive Order to Expand Apprenticeships On June 15, 2017, the President issued EO 13801,8 instructing the Department and

agencies across the Federal Government to take actions necessary “to provide more

affordable pathways to secure high-paying jobs by promoting apprenticeships and

effective workforce development programs, while easing the regulatory burden on such

programs.” The EO and this notice further the National Apprenticeship Act’s broad

instruction to bring together employers and labor to form apprenticeship programs.

(29 U.S.C. § 50.)

The EO required the establishment of a Task Force on Apprenticeship Expansion (Task Force) to identify strategies and recommendations to promote apprenticeships,

especially in sectors where apprenticeship programs are insufficient. The Task Force, comprised of 20 highly experienced members representing a balanced range of industries, occupations, and perspectives, met multiple times from November 2017 to May 2018. The Task Force’s subcommittees presented their recommendations and rationales to the full Task Force, which deliberated and voted to send the recommendations to the President in its Final Report. The Department has been

6 Task Force on Apprenticeship Expansion, Final Report to the President of the United States, p. 40, available at

https://www.dol.gov/apprenticeship/docs/task-force-apprenticeship-expansion-report.pdf (“Final Report”). 7 See generally U.S. Department of Labor, BLS, Occupational Outlook Handbook, available at

https://www.bls.gov/ooh/. 8 The full text of EO 13801 is available at https://www.whitehouse.gov/the-press-office/2017/06/15/presidential-

executive-order-expanding-apprenticeships-america.

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informed by, and incorporated herein, many of the recommendations of the Task Force.

The Final Report’s Recommendation 1 suggested that Industry-Recognized

Apprenticeship Programs serve as a vehicle to “expand more traditional work-and-learn

models to incorporate the criteria of modern apprenticeship.”9 The Department agrees

with and supports the recommendation, consistent with the directives of the EO.

Workers and employers in many areas of the economy may benefit from greater use of

high-quality apprenticeship programs, particularly where apprenticeships have

traditionally been rare.

What Are Industry-Recognized Apprenticeship Programs and Standards Recognition

Entities?

Industry-Recognized Apprenticeship Programs are high-quality apprenticeship

programs that include a paid-work component and an educational or instructional

component, wherein an individual obtains workplace-relevant knowledge and

progressively advancing skills, and that result in an industry-recognized credential. An

Industry-Recognized Apprenticeship Program is developed or delivered by entities such

as trade and industry groups, companies, non-profit organizations, educational

institutions, unions, and joint labor-management organizations, and is one that has the

hallmarks of a high-quality program outlined below.

Such programs conform with the standards for training, structure, and curricula that

SREs have established and are subject to SREs’ monitoring and quality assurance

processes. The Department does not limit the types of entities that may seek a favorable

determination under this TEN and believes that many different types of entities can and

should function as SREs. SREs may include but are not limited to: trade, industry, and

employer groups and associations; companies; certification bodies; educational

institutions (such as universities or community colleges); state and local government

agencies or entities; non-profit organizations; unions; joint labor-management

organizations; or a consortium or partnership of entities such as those listed above.

SREs may be pre-existing organizations or may be created for the express purpose of

recognizing Industry-Recognized Apprenticeship Programs as having the hallmarks of

high quality.

DOL will issue a letter indicating whether SREs meet certain criteria of quality. These

criteria, set out below, are the pillars supporting the high-quality apprenticeship

programs that will promote a skilled workforce and open more pathways to great

careers through the expansion of traditional apprenticeship models to new industries

and occupations. In addition, the Department believes these types of SREs could

enhance the development of innovative means of making apprenticeship programs, or

components of such programs, more affordable for employers through the use of virtual

learning, public availability of core foundational elements shared between programs,

and greater efficiency in consolidating redundancies.10

9 Final Report, Recommendation 1, p. 21. 10 Final Report, Recommendation 5, p. 24-25.

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Getting Started

SREs will be able to submit to the Department a description of their approach to

developing and validating standards for and then recognizing and monitoring Industry-

Recognized Apprenticeship Programs—a submission that the Department will evaluate for

consistency with the criteria set out in this revised TEN and reflected in the revised

application form to be posted on www.apprenticeship.gov. SREs that intend to take

advantage of this opportunity to receive a favorable determination should continue to

develop plans, structures, and processes that assume impartiality, confidentiality and

objectivity, and key partnerships that will lead to the development of high-quality

apprenticeship programs.

An SRE will receive a favorable determination if it demonstrates that it meets the

following criteria:

1. Expertise in Setting Standards. The SRE must show that it has the expertise to

set standards, through a consensus-based process involving industry experts, for

requisite training, structure, and curricula for apprenticeship programs in the

industry(ies) or occupational area(s) in which it will recognize Industry-

Recognized Apprenticeship Programs. An SRE should demonstrate sufficient

support and input from industry experts to give confidence in the SRE’s

expertise, given where its programs will operate.11 The Department anticipates

that this process will result in clear standards reflecting the competencies needed

for proficiency in any given industry or occupational area. The Department notes

and appreciates that some SREs already have standards-setting processes that

reflect well-established industry-, occupation-, and employer-specific needs and

skills. Rather than requiring those SREs to alter their approaches to setting

standards, the Department seeks to clarify here the expectation that such entities’

processes for setting standards may already have the characteristics this TEN

describes. The Final Report’s Recommendation 19 suggested that the

Department solicit proposals for industry-sector oversight bodies to avoid the

problem of multiple groups within a sector promulgating conflicting or

inconsistent standards. Likewise, the Final Report’s Recommendation 20

suggested that these same bodies be responsible for developing credentialing

standards. The Department has concerns about the propriety of designating a

single industry oversight body or requiring agreement and uniformity of

standards as a condition of receiving a favorable determination as an SRE.

Though the Department believes that sector-wide consortia with uniform

standards will have broad appeal to potential apprentices and employers, the

Department believes that the criteria set forth herein will result in effective

competency-based standards and high-quality programs.

11 Although DOL anticipates that most SREs will recognize programs developed in specific industries, some

occupations within programs may exist across industries. Identical standards may be appropriate for such cross-

industry occupations.

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2. Clear Policies and Procedures for Recognizing Industry-Recognized

Apprenticeship Programs. An SRE’s policies and procedures for recognizing apprenticeship programs as high-quality programs should be sufficiently detailed so that entities seeking to establish Industry-Recognized Apprenticeship Programs

will be assured of equitable treatment and will be evaluated based on the merits of

their programs. An SRE should recognize or reject a program seeking recognition in a timely manner; should not provide recognition for longer than five years unless a program seeks re-recognition; and should not place barriers on a program’s receiving recognition from another SRE. An SRE should also have an ongoing quality-control relationship with programs it has recognized. The Department will have detailed questions concerning the nature of an SRE’s recognition processes in the revised application form associated with this TEN.

3. Transparency and Accountability. An SRE should be transparent and

accountable, and should ensure those characteristics in the programs it recognizes

as high quality. An applicant’s explanation of its approach to meeting the

following expectations will inform DOL’s assessment on this point. First, an SRE

should expect to make publicly available up-to-date contact information for all of

the Industry-Recognized Apprenticeship Programs it has recognized. Second, each

SRE should publish for each program the number of individuals who began the

program annually and completed the program annually, as well as the annual

completion rate, median length of time for program completion, and the post-

apprenticeship employment rate of apprentices at completion.12 This information is

important for providing employers and prospective apprentices with details

necessary to assess and make informed decisions about Industry-Recognized

Apprenticeship Programs.

4. Impartiality, Confidentiality, Objectivity, and Independence. SREs must

ensure that recognition decisions are impartial, based on objective criteria, and are

confidential. SREs must also be independent in their partnerships or otherwise

take steps to mitigate any potential conflicts of interest via specific policies,

processes, procedures, and/or structures. These requirements ensure the quality of

the standards-setting and recognition processes that lead to high-quality Industry-

Recognized Apprenticeship Programs.

5. High-Quality Apprenticeship Programs. An SRE should ensure that

apprenticeship programs it recognizes adhere to hallmarks of the highest

quality. As part of this showing, an SRE should demonstrate that it has the

capacity and quality assurance processes and procedures needed to

recognize and monitor its programs for high quality, given their scope.

These hallmarks of high quality include the following elements:

Paid Work Component. An SRE should require that Industry-Recognized

Apprenticeship Programs ensure apprentices are paid at least the applicable

12 Final Report, Recommendation 8, pp. 28-29.

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Federal, State, or local minimum wage. The Final Report Recommendation

18 suggested that, although Industry-Recognized Apprenticeship Programs

are not required to follow specific wage progression rules, they should

“make clear to apprentices what wages they will be paid and under what

circumstances wages will increase.”13 Accordingly, Industry-Recognized

Apprenticeship Programs should describe the wages to be paid during the

apprenticeship and under what circumstances those wages will increase.

Programs should also disclose any ancillary costs or expenses that

apprentices may be charged so that apprentices can accurately calculate their

anticipated earnings.

Work-Based Learning. An SRE should explain its policies and practices

for ensuring the apprenticeship programs it recognizes will have structured

work experiences for apprentices, as endorsed by the Final Report’s

Recommendation 16. This requirement is “[f]undamental to the success of

apprenticeship.”14 Such experiences help apprentices master industry-

essential skills in the context of an employment relationship, and equip them

for jobs that require specialized knowledge and experience and involve the

performance of complex tasks.

Mentorship. An SRE should ensure that apprenticeship programs it recognizes

as high-quality programs have structured mentorship opportunities for

apprentices, as endorsed by the Final Report’s Recommendation 2(D). Such

mentorship opportunities should support apprentices during their work-based

learning experiences and can provide guidance on industry or company culture,

specific position functions, and industry or workplace policies and

procedures.15

Educational and Instructional Component. As suggested in the Final Report,

an SRE must explain how it will ensure that the apprenticeship programs it

recognizes will provide or arrange for classroom or related instruction that is

appropriate and adequate to help apprentices achieve proficiency and earn

credentials.16 If an apprenticeship program does not itself provide such

instruction, the SRE should explain how it will require programs to identify the

specific potential educational partners, such as community colleges, vocational

and occupational schools, or any other entities qualified to provide the

instruction, and provide related information about such entities and the

education they would provide. SREs should encourage the provision of credit

for prior knowledge and experience for apprentices in the apprenticeship

programs they recognize, as endorsed by the Final Report’s Recommendations

2(B) and 11(D). The Department believes that the recognition of prior

knowledge and experience will have many economic benefits. Workers with

13 Final Report, Recommendation 18, p. 35. 14 Final Report, Recommendation 16, p. 35. 15 Final Report, p. 41. 16 Final Report, Recommendations 2 and 3, pp. 22-23; see also p. 41.

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appropriate prior knowledge and experience and who can pass the necessary

skills assessments, certification exams, or other processes for credentialing,

should receive appropriate credit without unnecessary prerequisites such as a

certain number of hours of “seat time” or perfunctory classes.17 Fast-tracking

such workers allows them to immediately work fully, frees them from

unnecessary training and arbitrary requirements, and directs employers and

workers to the productive activities of their firms.18 The Department notes that

the Final Report’s Recommendation 20 encourages SREs to take an active role

in pursuing options for apprentices to obtain college credit through the ability

to “influence or negotiate with employers and colleges to partner on transfer or

credit agreements before verification of the credentialing standard.” The

Department supports the ability of entities to freely enter into such agreements

and recognizes such agreements may make programs that adopt them more

attractive to potential apprentices. The Department, however, does not believe

that such a condition is in the best interest of broad adoption of Industry-

Recognized Apprenticeship Programs.

Industry Credentials Earned. An SRE should disclose the industry-

recognized credential(s) that apprentices will earn during or upon successfully

completing an Industry-Recognized Apprenticeship Program. A credential can

be a certificate, certification, degree, electronic badge, or other indicator that

attests to an individual’s acquisition of skills or knowledge. An industry-

recognized credential is one that is created by the industry that will use the

credential, based on the particular competencies required within the specific

industry. These credentials may consist of a certificate of completion or a

certification issued by the SRE of an Industry-Recognized Apprenticeship

Program, for example. In industries in which generally accepted credentials

already exist or will be issued by industry organizations or personnel

certification bodies, SREs should demonstrate their policies and procedures for

ensuring that programs they recognize will lead to receipt of one or more of

these existing credentials or qualify a program participant to sit for relevant

certification exams. As endorsed by the Final Report’s Recommendation 3,

SREs should ensure that instruction and work-based learning outcomes align so

that apprentices are adequately prepared to earn an industry-recognized

credential. The Final Report’s Recommendation 4 further elaborated on what

the Task Force viewed as useful criteria for credentials, including that

credentials have a foundation in industry-developed standards and are tied to

competency models. And Final Report Recommendation 15 suggests that

“apprenticeship programs should focus on mastery and competency, not just

seat-time or training hours.” Again, credentials that are industry-recognized are

developed based on the competencies or skills apprentices must learn to do

their jobs well.19 By contrast, credentials based on an arbitrary number of

17 Final Report, Recommendations 5 and 11(D), pp. 24, 32. 18 Final Report, Recommendation 5, p. 24. 19 Final Report, Recommendation 3, p. 23. Note that the Department anticipates that Industry-Recognized Apprenticeship Programs will generally provide credentials that are portable. A program may require apprentices to

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hours, which have little connection to real-world work, or that serve

predominantly as a means to collect fees, raise barriers to entry, or simply to

perpetuate a credentialing body are less likely to meet the Department’s criteria

of validity and quality.20

Safety and Supervision. As suggested by the Final Report, SREs must describe

in detail the policies and procedures in place to ensure that programs provide a

safe working environment that adheres to all applicable Federal, State and local

safety laws and regulations.21 The Department notes that the EO instructs the

Department to promote apprenticeships in additional industry sectors,22 and the

Final Report’s Recommendation 1 suggests expanding more employer training

into the apprenticeship model. SREs should be prepared to address any unique

safety issues that arise in their programs’ industries or occupations.23

Equal Employment Opportunity Obligations. An SRE should have policies

and procedures that would require Industry-Recognized Apprenticeship

Programs to protect apprentices from discrimination, and should assist in

recruiting for and maximizing participation in apprenticeships. An SRE

accordingly should:

o Have policies and procedures that require Industry-Recognized

Apprenticeship Programs’ adherence to applicable Federal, State, and

local laws pertaining to Equal Employment Opportunity;

o Facilitate such adherence by Industry-Recognized Apprenticeship

Programs through the SRE’s policies and procedures regarding potential

harassment, intimidation, and retaliation; o Have policies and procedures that reflect comprehensive outreach

strategies to reach diverse populations that may participate in Industry-Recognized Apprenticeship Programs; and

o Assign responsibility to an individual to assist Industry-Recognized Apprenticeship Programs with matters relating to Equal Employment Opportunity.

What Happens After I Request a Favorable Determination from DOL?

Upon receiving a submission seeking a favorable determination, DOL will assess

whether that entity has made a showing consistent with the criteria set forth above,

including whether the SRE has the capacity and quality assurance processes and

pass a nationally-recognized exam that measures competencies necessary for the apprentice’s occupation. That exam would enhance the apprentice’s mobility, and enhancing workforce mobility is a vital part of effectively addressing the skills gap. At the same time, the Department recognizes that providing a credential that is “portable” in the broadest sense may not always be possible. As a general matter, though, by requiring that credentials reflect the specific competencies needed for any given occupation, the Department anticipates that programs will enhance apprentices’ mobility. 20 Final Report, Recommendation 5, p. 24. 21 Final Report, Recommendation 16, p. 35. 22 E.O. § 6. 23 Final Report, Recommendation 16, p. 35.

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procedures necessary to ensure the apprenticeship programs it recognizes have the

hallmarks of high quality. Although there is no appeal process for a negative

determination issued pursuant to this TEN, the applicant may resubmit its application

with an explanation of any changes made since its last submission. An SRE should seek

an updated determination from the Department upon making substantive changes to its

recognition process (including seeking to recognize programs in additional industries or

occupational areas), or within five years after receipt of a favorable determination,

whichever is sooner. At the Department’s discretion, if it becomes apparent that an SRE

no longer fits within the framework this TEN outlines—including that it lacks the

policies and procedures necessary for the SRE to recognize only apprenticeship

programs with the hallmarks of high quality—the Department may issue a subsequent

determination describing where the SRE is misaligned with the requirements of this

TEN and reflected in its application form.

What Are the Differences Between Industry-Recognized Apprenticeships and

Registered Apprenticeships?

Industry-Recognized Apprenticeship Programs are distinct from Registered

Apprenticeship Programs established under current regulations at 29 CFR part

29. Such programs have been a successful fixture among traditional trades for

decades. The Registered Apprenticeship system will continue, and current and

prospective sponsors and apprentices will continue to enjoy its benefits.

Registered Apprenticeships are automatically eligible for inclusion on state

Eligible Training Provider lists under the Workforce Innovation and

Opportunity Act (WIOA) and are eligible for other statutory benefits, whereas

Industry-Recognized Apprenticeship Programs are not. Industry-Recognized

Apprenticeship Program participants cannot be considered as apprentices for the

purpose of meeting the Davis-Bacon Act wage requirements (as stated in Final

Report Recommendation 17).24

An Industry-Recognized Apprenticeship Program may choose to become a Registered

Apprenticeship Program as long as it meets the necessary standards and requirements,

and an existing Registered Apprenticeship Program may seek industry recognition

through an SRE. It is important to note, however, that the goal of the EO and this

guidance is to create an additional pathway to encourage the expansion of

apprenticeships beyond those industries where apprenticeships already are effective and

substantially widespread, and so the Department does not expect to have many if any

dual apprenticeship programs.

Will the Industry-Recognized Apprenticeship Program Begin as a Pilot Project?

The Final Report, in Recommendation 14, suggested that “[t]he Industry-Recognized

Apprenticeship program should begin implementation with a pilot project in an industry

without well-established Registered Apprenticeship Programs. This would test the

process for reviewing [SREs] and would help the Federal Government better understand

24 Final Report, Recommendation 17, p. 35.

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how to support industry groups working to develop standards and materials for

Industry-Recognized Apprenticeship Programs.”

As explained in the initial TEN, the Department has reviewed this recommendation and

agrees in part and disagrees in part. The large skills gap requires a more immediate

response than a pilot project would permit, yet there is a value to a parallel

apprenticeship system that proceeds without undermining pre-existing successful

efforts. The President’s EO, in fact, charged the Task Force to “identify strategies and

proposals to promote apprenticeships, especially in sectors where apprenticeship

programs are insufficient.” Registered Apprenticeships in the U.S. Military and in the

construction industry continue to account for the majority of federally registered

apprenticeships. Because these two contexts already have significant Registered

Apprenticeship opportunities, the Department will not accept applications from SREs

seeking to recognize apprenticeship programs in construction or the Military.25 This

will be reflected in the Department’s revised application form.

Regulations.

As stated above, the skills gap requires action. The Department has issued this revised

TEN to provide additional guidance for those organizations wishing to seek a favorable

determination from the Department concerning whether their policies and procedures

align with what this TEN delineates.

At the same time, the Department recently published a Notice of Proposed Rulemaking

(NPRM) and a proposed application form for the NPRM, both aligned with the types of

considerations and requirements this TEN delineates. Until that rule and its proposed

application form are finalized, the Department will proceed to receive submissions from

entities interested in seeking favorable determinations under this revised TEN and its

associated form. As explained above, to the extent the application form approved for the

final rule differs from the form associated with this TEN, the final rule may provide that

entities that have received a favorable determination under this TEN provide updated

application information to the Department. In the interim, the Department believes this

revised TEN provides valuable guidance to entities that seek to act now.

Why Get Involved with Industry-Recognized Apprenticeship Programs?

Benefits of involvement with the new Industry-Recognized Apprenticeship initiative

include:

Build a Pipeline of Skilled Talent to Meet the Needs of Your Industry. Many

industries today face workforce challenges due to a skills gap. By assisting in the

establishment of an SRE, you can help obtain a consistent pipeline of talented

workers for your industry or occupation. Likewise, by helping establish an Industry-

25 An apprenticeship program is in the construction industry if it equips apprentices to provide labor whereby

materials and constituent parts may be combined on a building site to form, make, or build a structure. See Union

Asphalts & Roadoils, Inc. v. MO-KAN Teamsters Pension Fund, 857 F.2d 1230, 1234 (8th Cir. 1988). An

apprenticeship program is in the U.S. Military if it provides a credential to members of the U.S. Military based on

their military training and experience.

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Recognized Apprenticeship Program, you are serving as a leader for your industry,

creating economic benefits for your organization, and helping the country and

industry become more economically competitive and dynamic.

Help Develop Sector-Driven Standards. To receive a favorable determination under

this TEN, SREs should draw from expertise within the relevant industry or

occupation. Experts and employers familiar with each industry or occupation should

determine the competencies required of their future workforce and how best to teach

those skills in apprenticeship programs. If you believe your organization has insight

into what skills an apprentice in your field should have, you should consider becoming

or establishing an SRE.

Build the Future of Apprenticeship. Pursuant to the President’s EO, DOL continues

to take a close look at what needs to be done to expand apprenticeship as a valued and

high-quality pathway into the skilled workforce. To succeed, this program must be

industry-led and market-driven. Your organization’s involvement will help expand the

apprenticeship model to new industries and occupations.

How Can the Effectiveness of Industry-Recognized Apprenticeships Be Assessed?

SREs will play an important role in gathering and publishing data concerning

Industry-Recognized Apprenticeship Programs, as explained above. Such information

about programs will provide valuable information to apprentices and employers. In

addition, as a means of evaluating effectiveness and broadening awareness of the

benefits of the apprenticeship model, SREs could produce industry-wide case studies

to help companies quantify the return on investment for apprenticeship programs and

encourage expansion of the apprenticeship model. SREs could demonstrate metrics

and specific data sets to indicate their programs’ success, as well as showcase proof of

concept (as suggested by the Final Report in recommendation 8).26

What Assistance Will Standards Recognition Entities Offer Apprenticeship Programs and

Employers?

SREs are expected to offer apprenticeship programs and employers competency-based

standards for training, structure, and curricula that result in high-quality programs and equip

apprentices with the skills needed for long-term career success. The Department encourages

SREs to continue developing off-the-shelf products to reduce the burden and expense for

employers that seek to quickly develop and start such programs. For instance, an SRE may

develop its own online instruction modules that apprenticeship programs may use; a

framework of recommended courses and curricula for apprentices; or a network of

educational providers to which employers and apprentices may be directed for the

instructional component of an apprenticeship program. These products and services will

enhance the high quality of Industry-Recognized Apprenticeship Programs and, ultimately,

reduce the burden and expense of starting a new apprenticeship program, particularly for

smaller companies and other entities that may need workers but lack the resources to develop

a new program from the ground up. At the same time, the Department anticipates that its

application’s rigorous disclosure requirements will ensure that SREs offering such services

26 Final Report, p. 28-29.

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and products mitigate any conflicts of interest and ensure the high quality of apprenticeship

programs.

4. Next Steps and Inquiries.

The Department believes the features of SREs outlined above—and the hallmarks of the

high-quality programs they would recognize—provide a strong framework for

expanding high-quality apprenticeships to new industries and occupations. The

Department also looks forward to the experimentation and innovation that SREs will bring

as apprenticeship increasingly becomes a well-trod pathway to rewarding careers.

The Department will be accepting applications from organizations seeking to receive a

favorable determination from the Department under the process set out in this TEN and

will announce the availability of that application form on www.apprenticeship.gov.

Interested parties may also submit comments or information (including statements of

interest) to apprenticeship@dol.gov.